Nowhere does Dr. Caulfield disclose whether he has a conflict of interest in this matter, nor the basis for his interest in undermining Canadian’s access to healthcare choice. Caulfield continues a pattern of biased and blatant cheerleading for the pharmaceutical industry, and the vaccine industry in particular. Caulfield assumes the allopathic understanding of the disease phenomena is the only valid understanding.

Dr. Caulfield rightfully recognizes that Naturopathic medicine represents a threat to the pharmaceutical industry’s efforts to create a medical monopoly. Canadians are increasingly seeking alternatives to the artificial stimulation of the immune system that is the basis of vaccination.

The medical journal, Pediatrics, reports that the number of pediatricians encountering parents who question vaccine safety, refuse one or more vaccines, or want to use an alternative vaccination schedule increased from just under 75% in 2006 to 87% by 2013. The number of parents questioning vaccine safety, effectiveness, and necessity is even higher today.

No Evidence of Consumer Dissatisfaction

Caulfield’s considerable efforts to undermine and eliminate medical choice doesn’t appear to be motivated by consumer dissatisfaction of Naturopathic Physicians, or evidence of harm from Naturopathic treatment. Instead Caulfield appears to be motivated by his unwillingness to allow Canadians medical choice outside of allopathic medicine.

In his submission in the Journal of Law and the Biosciences entitled, “Injecting doubt: responding to the naturopathic anti-vaccination rhetoric”, Caulfield operates from the premise that the growing doubt about vaccination safety and effectiveness is caused by Naturopaths. Caulfield assumes that by eliminating Naturopathic medical care, he will eliminate any doubt about vaccine safety and effectiveness.

Caulfield fails to understand that the considerable concern and doubt about vaccination safety and effectiveness is a result of growing dissatisfaction with the artificial immunization paradigm. Health consumers are seeking alternatives to vaccination due to the significant harm and injuries caused by vaccines.

The extent of harm is evident by the more than $3.6 Billion in compensation paid by the US Vaccine Injury Compensation Program to date. Canada, to its discredit, is the only G7 Nation without a national vaccine injury compensation program. Canada is the outlier here, not recognizing and compensating for vaccine injury and death.

Baseless Claims

Caulfield opinions that Naturopaths “make baseless claims about how to naturally “boost” your immune system”. Nowhere in Caulfield’s research does he provide evidence of how these claims are baseless. Instead, we are simply asked to accept Caulfield’s opinion on a matter he knows virtually nothing about.

Caulfield implies that vaccination is the only means of developing immunity. This shows a disturbing ignorance of the human body and its innate immune system. Caulfield can be forgiven for mistakenly assuming vaccination equals immunity as the vaccine industry has acted as if they are one and the same.

Caulfield Spreads Myths and Misinformation

Caulfield accuses Naturopaths of spreading myths and misinformation about vaccine safety. It is Caulfield who continues to spread myth and misinformation in spite of repeated efforts to educate Dr. Caulfield on these matters.

Caulfield states – “Some of the clinics offer warnings about how vaccines contain mercury and/or reference the frequently debunked myth that vaccines are linked to autism.” Caulfield’s statement implies there is no mercury in vaccines, and that there is no evidence to support a vaccine – autism link. Neither of these statements is supported by the evidence.

Vaccines Contain Mercury

Caulfield continues to show willful blindness to the fact that some vaccines licensed in Canada do contain mercury. Vaccine manufacturers use mercury (Thimerosal) in the manufacture of many vaccines, and as a preservative in multi-dose vials. The presence of mercury can be easily verified from the product information inserts provided with each vaccine product, or by checking the Canadian Immunization Guide.

Canada permits the use of mercury containing multi-dose vials of the influenza vaccine and even encourages this neurotoxic substance be injected into pregnant mothers and infants as young as six months.

Mercury is the most toxic substance that is not radioactive. It is scientific fact that human brain neurons permanently disintegrate in the presence of mercury. There is no evidence injected mercury is safe in any amount.

Vaccine – Autism Evidence

Caulfield also continues to make the claim that the vaccine – autism relationship has been “debunked”. Nothing could be further from the truth. Caulfield ignores the considerable and growing body of evidence of a vaccine-autism link. The body of evidence of a vaccine – autism link includes the following:

A report in the Pace Environmental Law Review Journal reviewed 83 cases of vaccine-induced brain injury that resulted in an autism diagnosis, which were compensated by the U.S. Federal Vaccine Injury Compensation system http://digitalcommons.pace.edu/pelr/vol28/iss2/6

William Thompson, a Senior Scientist with the Vaccine Safety Division of the CDC and the lead statistician and co-author of the 2004 CDC study that is used by vaccine proponents to deny a link between the MMR vaccine and autism took whistleblower status in 2014 to reveal CDC scientists colluded to commit scientific fraud in order to obscure the link between the MMR vaccine and autism.Dr. Thompson claims the federal agency ordered him and his colleagues to destroy study findings that confirmed a link between the MMR vaccine and autism. This alarming disclosure is the basis of the 2016 documentary Vaxxed: From Cover-Up to Catastrophe. The media, to its discredit, has actively tried to censor this film, refused to inform the public of this significant disclosure, and has failed to advocate for a full investigation of Thompson’s claims.

The Journal of Translational Science recently published the first privately funded study comparing the overall health of vaccinated and unvaccinated 6 to 12 year old children in the United States.The results reveal that while vaccinated children were significantly less likely to have chicken pox or whooping cough, they were significantly more likely to have pneumonia, allergies, otitis media (ear infection), eczema, a learning disability, Attention Deficit Hyperactivity Disorder, Autism Spectrum Disorder, neuro-developmental disorders, and chronic illness.

“The body of evidence on both sides is open to interpretation.People have every right to disbelieve the studies on one side.But it is disingenuous to pretend they do not exist.”

Ms. Attkisson’s comment applies directly to Dr. Caulfield’s statement denying any evidence of a vaccine – autism link. Caulfield has every right to disbelieve the studies on one side of the debate. But to claim the relationship between vaccines and autism has been “debunked” is dishonest and irresponsible journalism.

It would appear Dr. Caulfield is intentionally ignoring evidence of a vaccine – autism link with the express purpose of misleading the public. Anyone who makes the claim the vaccine – autism link is debunked is offering propaganda, not science.

Misleading, Harmful and Completely Unfounded

Caulfield makes the statement –

“One clinic suggests that “as an alternative to the flu shot, you can choose a homeopathic prophylactic injection instead” and another claims that “homeopathy flu injections” are a “safe and effective alternative to the regular flu shot.” These assertions are, of course, misleading, harmful and completely unfounded.”

Caulfield provides no evidence that these assertions are misleading, harmful or completely unfounded. For someone championing the importance of evidence, Caulfield shows an astonishing lack of evidence for his many assertions. Without evidence, why should we accept Caulfield’s opinions as valid?

The Theory of Herd Immunity

Caulfield continues to make the claim that any discussion about vaccine safety and effectiveness undermines herd immunity. Caulfield fails to acknowledge that herd immunity is a theory based on natural exposure, which produces natural life-long immunity.

The immune response stimulated by vaccines is temporary, lasting a few years or even as short as a few months. As much as 10% of the population may have no immune response to some vaccines. There is no evidence herd immunity can be achieved with vaccination, and the rate of vaccination needed to produce herd immunity is pure speculation and not evidence-based medicine.

Caulfield also fails to acknowledge that many vaccines are not designed to reduce the spread of disease, but rather to reduce the severity of symptoms should one get the disease. Vaccines for diphtheria, pertussis, injected polio, and influenza do not prevent transmission. Therefore vaccination with these vaccines has no impact on the rate of infection or herd immunity. Tetanus is not contagious and therefore a high rate of vaccination does not create herd immunity.

To suggest that non-vaccinating individuals undermine herd immunity is marketing propaganda, not science. Most disease outbreaks are due to vaccine failure, not a failure to vaccinate. Suggesting non-vaccinated individuals are a risk to the community is dishonest and fear mongering.

Caulfield Fails to Acknowledge Legitimate Concerns

Caulfield continually fails to acknowledge the legitimate concern about the safety of vaccination and shows callous disregard for those harmed and killed by vaccines. Dr. Caulfield chooses to ignore that the vaccine industry has been forced to withdraw numerous vaccines through out its history because of the significant harm these vaccines caused. The list includes: the small pox, swine flu, whole cell DPT, MMR (Urabe strain), and oral polio vaccines, among others.

Caulfield also chooses to ignore that a major criticism of the vaccine program is its systemic failure to conduct long-term clinical trials that scientifically prove the safety of the current vaccine program. The prestigious Institutes of Medicine (IOM) found that the safety of the current childhood vaccine schedule has never been proven in large, long-term clinical trials:

“The committee’s review confirmed that research on immunization safety has mostly developed around studies examining potential associations between individual vaccines and single outcomes. Few studies have attempted more global assessment of entire sequence of immunizations or variations in the overall immunization schedule and categories of health outcomes, and none has squarely examined the issue of health outcomes and stakeholder concerns in quite the way that the committee was asked to do its statement of task. None has compared entirely unimmunized populations with those fully immunized for the health outcomes of concern to stakeholders.”

Vaccines have not been tested for carcinogenicity – the ability to cause cancer, toxicity – the ability to damage an organism, genotoxicity – the ability to damage genetic information within a cell, mutagenicity – the ability to change the genetic information of an organism, the ability to impair fertility, or for long-term adverse reactions.

The current vaccine schedule has never been tested for safety in the real world way in which the schedule is implemented. No independent trials confirm the safety of giving multiple vaccinations at once. Research shows a dose-dependent association between the number of vaccines administered simultaneously and hospitalization or death. No long-term clinical evidence exists that show vaccinated children have better overall health than unvaccinated children.

This lack of scientific evidence of vaccine safety and effectiveness suggests vaccination is ideology rather than evidence-based medicine.

This begs the question why the resources of Caulfield and the research team at The Health Law Institute (HLI) aren’t addressing the misleading claims and harmful effects of the current vaccine program, given the significant user dissatisfaction and an abundance of evidence of harm.

The Need for Federal Regulators

There is one aspect where Caulfield has it right. We agree with Dr. Caulfield “that federal regulators need to be more aggressive in their application of truth in advertising standards.” The vaccine industry continues to make claims of safety, effectiveness, and necessity that are not evidence based.

Vaccine producers do not know the long-term impact vaccines have on our neurological and immune systems. This is because vaccine producers are not required to conduct long-term safety studies. Vaccine producers are not required to conduct vaccinated vs. unvaccinated studies. Vaccine producers are able to market their products with less safety testing and oversight than is required with any other pharmaceutical drug.

Manufacturers are not required to demonstrate vaccines actually reduce the rates of disease contraction, contagion, complication, or mortality. It is assumed that antibody titers equate to immunity despite the lack of supporting evidence.

Vaccines are the only medication where evidence of efficacy and absence of harm are not required before approval. Vaccine effectiveness ought to be evaluated based on evidence the vaccine actually prevented the targeted illness or improved health. This does not occur in the vaccine paradigm.

Without proper clinical studies, the whole premise of vaccination safety, effectiveness, and necessity is speculation rather than evidence based. Vaccination is effectively an uncontrolled and unmonitored experiment. This is unacceptable and needs to end. The vaccine industry claims that they are part of an evidence-informed profession. It’s time they proved it.

Third Party Oversight

We also support Caulfield’s call for third-party oversight to ensure adherence to science-based standards of practice. The Center for Disease Control has seriously conflicted interests. The CDC is responsible for vaccine safety at the same time they have a mandate to increase vaccine uptake.

The CDC is both a regulatory agency and a major player in the vaccine industry. The CDC is a private, for-profit corporation that holds patents on over 50 vaccines and sells more than $4.5 billion worth of vaccines each year.

Federal conflict of interest rules do not apply to the CDC. Those responsible for licensing vaccines routinely benefit from the sale of vaccines. The CDC cannot be trusted to provide independent and honest oversight of vaccine safety and effectiveness.

A third party, independent of industry, government, and media influence, is desperately needed.

Good Journalism on Vaccination

Dr. Caulfield would also be advised to consider the advice of Dr. Peter Doshi, Associate Editor for the British Medical Journal. Dr. Doshi makes the following statements about good journalism as it pertains to vaccinations:

Good journalism on this topic will require abandoning current practices of avoiding interviewing, understanding, and presenting critical voices out of fear that expressing any criticism amounts to presenting a “false balance” that will result in health scares.

. . . if patients have concerns, doubts, or suspicions — for example, about the safety of vaccines, this does not mean they are “anti-vaccine.”

“Approaches that label anybody and everybody who raises questions about the right headedness of current vaccine policies as “anti-vaccine” fail on several accounts.

Firstly, they fail to accurately characterize the nature of the concern. Many parents of children with developmental disorders who question the role of vaccines had their children vaccinated . . . and people who have their children vaccinated seem unlikely candidates for the title.

Secondly, they lump all vaccines together as if the decision about risks and benefits is the same irrespective of disease — polio, pertussis, smallpox, mumps, diphtheria, hepatitis B, influenza, varicella, HPV, Japanese encephalitis — or vaccine type — live attenuated, inactivated whole cell, split virus, high dose, low dose, adjuvanted, monovalent, polyvalent, etc.

This seems about as intelligent as categorizing people into “pro-drug” and “anti-drug” camps depending on whether they have ever voiced concern over the potential side effects of any drug.

Thirdly, labeling people concerned about the safety of vaccines as “anti-vaccine” risks entrenching positions. The label (or its derogatory derivative “anti-vaxxer”) is a form of attack. It stigmatizes the mere act of even asking an open question about what is known and unknown about the safety of vaccines.

Fourthly, the label too quickly assumes that there are “two sides” to every question, and that the “two sides” are polar opposites. This “you’re either with us or against us” thinking is unfit for medicine.

Contrary to the suggestion — generally implicit — that vaccines are risk free (and therefore why would anyone ever resist official recommendations), the reality is that officially sanctioned written medical information on vaccines is — just like drugs — filled with information about common, uncommon, and unconfirmed but possible harms.

Medical journalists have an obligation to the truth. . . . It’s time to listen—seriously and respectfully—to patients’ concerns, not demonize them.”

Caulfield’s persistent use of the terms “anti-vaccine” and “anti-vaxxer” are, as Doshi explains, a form of attack and needs to stop. This message of “you’re either with us or against us” is unfit for medicine.

Increasing Mistrust of Vaccine Science

Dr. Caulfield’s opinion is a classic example of how uninformed or misinformed journalists, no matter how well intended, actually undermine our confidence in the vaccine program by providing information that a simple search of the medical literature demonstrates to be inaccurate and dishonest. Such misinformation does more harm than good and undermines our trust in media and the vaccine industry.

The increasing mistrust of the vaccine industry and the growing movement of vaccine hesitancy is because this industry presents as definitive that which is not; it lacks honesty and transparency; and too many children are being harmed.

Much of what is offered as vaccine science is pseudo-science—marketing propaganda masquerading as science. The vaccine industry would be more worthy of trust if they were honest about the state of the science, or lack of science, as pertains to vaccination safety, effectiveness, and necessity.

We expect the Globe and Mail to be honest brokers of medical information, and advocates to safeguard and protect the rights and freedoms of Canadians, including the right to informed consent and the Charter rights to security of the person.

It is my expectation the Globe and Mail will retract the inaccurate and dishonest statements made by Dr. Caulfield and make a public correction, or print this document in response to the opinions of Dr. Caulfield.